Legal Opinion

Lakhani v. Comm'r

United States Tax Court

Decided March 11, 2014No. Docket Nos. 21212-10, 24563-11Published

For 2005-09, P, a professional gambler who bet on horse races, deducted his net wagering losses (either incurred during the year or carried over from prior years) in contravention of I.R.C. sec. 165(d). R disallowed those deductions and imposed an I.R.C. sec. 6662(a) accuracy-related penalty for all years.

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For 2005-09, P, a professional gambler who bet on horse races, deducted his net wagering losses (either incurred during the year or carried over from prior years) in contravention of I.R.C. sec. 165(d). R disallowed those deductions and imposed an I.R.C. sec. 6662(a) accuracy-related penalty for all years. P argues (1) he is entitled to deductions for pro rata shares of the track's "takeout" from the parimutuel betting pools, which would wholly or partially offset the disallowed net wagering losses for the years at issue and (2) I.R.C. sec. 165(d) unreasonably discriminates against business…

1Opinion of the Court

SHIRAZ NOORMOHAMED LAKHANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;

SHIRAZ LAKHANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Lakhani v. Comm'r

Docket Nos. 21212-10, 24563-11.1

United States Tax Court

142 T.C. 151; 2014 U.S. Tax Ct. LEXIS 7; 142 T.C. No. 8;

March 11, 2014, Filed

Decisions will be entered under Rule 155.

For 2005-09, P, a professional gambler who bet on horse races, deducted his net wagering losses (either incurred during the year or carried over from prior years) in contravention of I.R.C. sec. 165(d). R disallowed those deductions and imposed an…

2Cases cited14 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  3. Carmichael v. Southern Coal & Coke Co.Supreme Court of the United States · 1937
  4. Jonson v. Comm'rUnited States Tax Court · 2002
  5. Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003

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